Injection Moulding Classification Upheld Due to Integrated Polymer Processing Function

In re Adient India Private Limited (CAAR Mumbai)

The ruling held that a foam production line imported in CKD/SKD form qualifies as a complete injection moulding machine based on its functional characteristics and cumulative clamping force, making it classifiable under tariff 8477 10 00. It further confirmed that anti-dumping duty applies irrespective of assembly form, as the product falls within the notification’s scope based on functional identity and prescribed parameters.

The applicant filed an application before the Customs Authority for Advance Rulings (CAAR), Mumbai, seeking clarification on the classification and applicability of anti-dumping duty (ADD) on the import of a “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine).”

The applicant is engaged in manufacturing automotive seat systems and proposed to import the subject machine from China in CKD/SKD condition, with all components presented together for clearance. The machine consists of two main parts: a metering machine and a dry side system. The metering machine stores and mixes polyol and isocyanate under controlled conditions, which are then dispensed into moulds via robotic systems. The dry side includes a conveyor system with 32 mould carriers, where moulds are filled, heated, subjected to clamping force, and processed to produce polyurethane foam.

The applicant argued that the machine should be classified under Heading 8477 as machinery for working plastics. It contended that the machine qualifies as an injection moulding machine under tariff entry 8477 10 00, being a reaction injection moulding system. Alternatively, it proposed classification under residual entries such as 8477 59 00, 8477 80 90, or even 8479 89 99. The applicant also relied on Rule 2(a) of the General Rules for Interpretation (GRI), stating that goods imported in CKD/SKD condition should be classified as complete machines.

On the issue of anti-dumping duty, the applicant argued that ADD under Notification No. 21/2025-Customs (ADD) would not apply because the machine’s clamping force was only about 8.02 tonnes (or 16.32 tonnes considering dual capacity), which is below the threshold of 40 tonnes specified in the notification.

The Authority examined the technical characteristics and functioning of the machine. It observed that the system performs automated moulding of polymer products by injecting reactive materials into mould cavities, followed by chemical reaction, shaping, and solidification within the mould. The process involves essential elements of injection moulding, including injection, moulding, clamping, and curing.

The Authority held that Heading 8477 covers machinery for manufacturing products from plastics, and polyurethane foam qualifies as a plastic product. Therefore, the subject machine falls within this heading.

On classification under tariff entry 8477 10 00, the Authority concluded that the machine satisfies the essential characteristics of an injection moulding machine. It noted that injection moulding includes reaction injection moulding, where liquid components are injected into a mould and react to form a solid polymer. The presence of injection/metering systems, moulding units, clamping mechanisms, and control systems confirmed that the machine is a complete injection moulding system.

The Authority rejected alternative classifications under residual entries such as 8477 59 00, 8477 80 90, and 8479 89 99, holding that when a product is clearly classifiable under a specific entry, resort to residual entries is not permissible.

Regarding Rule 2(a) of GRI, the Authority accepted that goods imported in CKD/SKD condition with all components together must be classified as complete machinery, since they possess the essential character of the finished product.

On the applicability of ADD, the Authority analyzed Notification No. 21/2025-Customs (ADD), which imposes duty on plastic processing or injection moulding machines with clamping force between 40 and 1500 tonnes, including those imported in CKD/SKD condition.

The Authority rejected the applicant’s contention that clamping force should be assessed per mould. It held that the machine is a multi-station integrated system with 32 mould carriers operating simultaneously. Therefore, clamping force must be assessed cumulatively across all stations. Each station has a clamping force of approximately 16.32 tonnes, resulting in an aggregate clamping force of about 522.24 tonnes.

Since this cumulative clamping force falls within the prescribed range of 40–1500 tonnes, the machine satisfies the criteria for levy of ADD.

The Authority further held that the notification is broad and technology-neutral, covering all forms of injection moulding machines, including those imported in CKD/SKD condition. It emphasized that classification or fragmentation of the machine cannot be used to avoid ADD liability.

Accordingly, the Authority ruled that:

1. The subject goods are classifiable under tariff item 8477 10 00 as injection moulding machines.

2. The goods, being imported in CKD/SKD condition, are to be treated as complete machines.

3. The machine falls within the scope of Notification No. 21/2025-Customs (ADD).

4. Anti-dumping duty is applicable, and imports attract ADD at the applicable rate (63% of CIF value for unspecified producers).

Classification of “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering M Read More..

FULL TEXT OF THE ORDER OF CUSTOMS AUTHORITY OF ADVANCE RULING, MUMBAI

Advance Ruling

Adient India Private Limited (having IEC No. 3195009595) (hereinafter referred to as ‘the applicant’, in short) filed application (CAAR-1) for advance ruling before the Customs Authority for Advance Rulings, Mumbai (CAAR in short). The said application was received in the secretariat of the CAAR, Mumbai on 07.11.2025 along with enclosures in terms of Section 28H (1) of the Customs Act, 1962 (hereinafter referred to as the ‘Act’ also).

2. The applicant is seeking advance ruling for Classification of “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine) (Part No. CAP0003805)” (hereinafter referred to as “the subject goods” or “product” or “Foam Manufacturing Machine”) to be imported by the Applicant and applicability of anti-dumping duty on the same.

3. Submission by Applicant-

3.1. Adient India Private Limited is a private limited company incorporated under the Companies Act, 1956.

3.2. The Applicant is engaged in the manufacture and supply of complete seat systems and its assembly for four-wheeler motor vehicle. The Applicant is a major supplier of automotive seats for the leading Original Equipment Manufacturers (“OEMs”) and also their suppliers in India.

3.3. The Applicant is proposing to import Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine) (Part No. CAP0003805) from China from supplier namely Krauss Maffei Machinery (China) Co. Ltd. The applicant has submitted a copy of the purchase order.

3.4. The machine will be imported in CKD/SKD condition and all the parts required for making the machine will be presented for clearance at the same time. The machine comprises of two major parts which are as follows:

i. Metering machine

ii. Dry side.

The applicant submitted various details of the subject goods viz… Copy of catalogue of metering machine and dry side, technical details of the machine and Process flow of the machine with its application.

Metering machine detail:

3.5. Metering machine comprises of four day-tanks with capacity of 500 liters each, high pressure metering pumps, mixing heads and hydraulic pumps.

3.6. Polyol is stored in three of the four day tanks and isocyanate is stored in one day tank. Each day-tank contains different type of polyol. Each day tank is connected through pipes separate high-pressure metering pump.

3.7. High-pressure metering pump is connected through pipes to two mixing heads. The function of high-pressure metering pumps is to circulate the chemical at 150 bar pressure.

3.8. Mixing head is hydraulically operated and is affixed on robot. Pre-decided quantity of chemical (i.e. isocyanate & polyol) is released in mixing head from high-pressure metering pump to form chemical composition/mixture required for manufacturing the polyurethane foam (PUR).

3.9. Each mixing head is connected to a robot. The robot automatically releases the mixture in the moulds for making PUR. A diagram providing the process followed by metering machine is provided below:

3.10. Metering machine also comprises of electrical switch gear & electronic devices like PLC, HMI which control the chemical temperature, flow & safety interlocks to avoid abnormal operations. Further, metering machine also comprises of electromechanical devices like chemical heat exchangers, flow meters, chemical level sensors, pressure transducers etc. Photographs of metering machine are provided below:

Dry side:

3.11 Dry side comprises of the carriers, oval conveyor, gear box, drive chain, water heater and a mechanical steel structure for rotating the carrier in oval path.

3.12 There are 32 carriers in dry side and moulds are fitted on each such carrier. The carriers are moving part which are connected by chain link and it keeps moving continuously while the machine is functioning. Carrier can carry mould weight of 700 kg.

3.13 Carriers move on an oval shape conveyor at speed of 10 meter/min to 12.5 meter/min. The carrier movement is controlled by electrical switch gear & electronic devices like PLC & HMI.

3.14 Carrier takes the mould at pouring station where robot pours the mixture in mould. After pouring, the mould is closed by the carrier.

3.15 Moulds are required to be heated up to temperature of 55 to 75 degree Celsius by water heating units for manufacturing PUR. Water heating units are installed on oval shape racetrack which are linked with carriers & moving continuously with carriers. Water heating units circulates hot water into moulds to heat up the moulds.

3.16 Further, clamping force of 80 kilo newtons (approximately 8.02 tonnes) is also required to be applied for manufacturing PUR.

3.17 Once the above process of pouring, heating and applying clamping force is completed and after one round completion, carrier comes in operator area where it starts opening the mould to allow the operator to take out the PUR foam from mould and the cycle continues. Photographs of dry side are provided below:

Imposition of Anti-dumping duty on import of plastic processing machinery or injection moulding machines falling under tariff entry 8477 10 00 and 8477 90 00.

3.18 Vide Notification No. 21/2025-Customs (ADD) dated 26.06.2025, the Central Government has imposed Anti-Dumping Duty (“ADD”) on import of plastic processing machines or injection molding machines used for processing and molding of plastic materials falling under tariff entry 8477 10 00 and 8477 90 00.

3.19 As per Note 2 of Notification No. 21/2025-Customs (ADD) dated 26.06.2025 ADD will be levied on all kinds of plastic processing or injection molding machines having a clamping force not less than 40 tonnes and not more than 1500 tonnes.

4. Applicants’ interpretation of Law:-

4.1 CLASSIFICATION OF FOAM MANUFACTURING MACHINE IN QUESTION IN THE PRESENT APPLICATION.

a. The foam manufacturing machine in question satisfies the criteria under tariff entry 8477 10 00 to be regarded as injection moulding machine for the manufacture of products from plastic.

4.1.1 The present application is inter-alia concerned with the appropriate classification of foam manufacturing machine. Heading 8477 of the First Schedule to the Tariff covers “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter”.

4.1.2 The Tariff is aligned, up to the 6-digit level, with the Harmonized System of Nomenclature (hereinafter referred to as “HSN”) issued by the World Customs Organization (hereinafter referred to as “WCO”). The HSN Explanatory Notes released by the WCO aid in the interpretation of the Headings of the Tariff and may be used as a safe guide for the same. It has been held so by the Hon’ble Supreme Court in the case of CC vs. Business Forms — 2002 (142) ELT 18 (SC).

4.1.3 The classification of the goods under the Tariff is governed by the principles enumerated in the General Rules of Interpretation (“GRI”) set out in the Tariff.

4.1.4 As per Rule 1 of the GRI, classification of the products shall be determined according to the terms of the headings and any relative Section or Chapter Notes. If the goods cannot be classified solely based on GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRI may then be applied.

4.1.5 Heading 847^–7 covers “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter”. The relevant entries of Heading 8477 are extracted below:

8477		Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter
8477 10 00	–	Injection-moulding machines
8477 20 00	–	Extruders
8477 30 00	–	Blow moulding machines .
8477 40 00	–	Vacuum moulding machines and other thermoforming machines
	–	Other machinery for moulding or otherwise forming:
8477 51 00	– –	For moulding or retreading pneumatic tyres or for moulding or otherwise forming inner tubes
8477 59 00	– –	Other
8477 80	–	Other machinery:
8477 80 10	– – –	Machinery for making rubber goods
8477 80 90	– – –	Other
8477 90 00	–	Parts

4.1.6 As provided above, polyol is mixed with isocyanate in pre-decided quantity for manufacturing the PUR. Polyol is classifiable under tariff entry 3907 29 10 of the First Schedule to the Tariff. It is submitted that Chapter 39 of Schedule I of the Tariff provides for “Plastic and articles thereof’.

4.1.7 Accordingly, it is submitted that as the polyol used in manufacturing of PUR is a type of plastic, the machine imported by the Applicant falls under CTH 8477 as the said CTH covers machinery for the manufacture of products from plastics. Thus, the foam manufacturing machine merit classification under CTH 8477.

4.1.8 Further, tariff entry 8477 10 00 provides for “Injection-molding machines”. It is submitted that final finding report dated 27.03.2025 in Case No. ADD (0.I.) 08/2024 issued by Directorate General of Trade Remedies provides for the meaning of injection moulding machines. It provides that injection moulding machine is a specialized industrial machine which is used to manufacture plastic products by the process of injection molding. The report also provides that injection moulding is manufacturing process where molten plastic is injected into a mould cavity, cooled, and solidified to form a finished shape/product. Relevant extract of the report is provided below for the ease of reference:

“12. A plastic processing machine, commonly known as an injection molding machine, is a specialized industrial machine used to manufacture plastic products by the process of injection molding. Injection molding is manufacturing process where molten plastic is injected into a mold cavity, cooled, and solidified to form a finished shape/product. Plastic processing machine offers the benefit of high production efficiency, and the ability to produce complex shapes with tight tolerances with minimal waste.”

4.1.9 It is submitted that there are various types of injection moulding machines which inter alia includes “Reaction Injection Moulding Machines”. In common parlance, reaction injection moulding machine means a machine which uses low-pressure and low-temperature process that mixes two reactive liquid components (like polyol and isocyanate) and injects them into a mould, where they chemically react and solidify into a finished polymer.

4.1.10 In the present case, polyol and isocyanate are mixed in pre-decided quantity in the mixing head, which is connected to a robot. The robot automatically pours the mixture into the moulds, after which the moulds are heated up to temperature of 55 to 75 degree Celsius by water heating units and clamping force of 80 kilo newtons (approximately 8.02 tons) is applied for manufacturing PUR. Therefore, the foam manufacturing machine imported by the Applicant satisfies the criteria of a reaction injection moulding machine.

4.1.11 In light of the above, it is submitted that foam manufacturing machine imported by the Applicant is an injection moulding machine and accordingly, classifiable under the tariff entry 8477 10 00 i.e. “Injection-moulding machines”.

b. Without prejudice to the above, the foam manufacturing machine can be classified under tariff entry 8477 59 00.

4.1.12 Without prejudice to above, it is submitted that the foam manufacturing machine can be classified under tariff entry 8477 59 00.

4.1.13 As provided above, foam manufacturing machine falls under the CTH 8477 as the said CTH provides for machinery for the manufacture of products from plastics and the machine is not specified or included elsewhere in Chapter 84.

4.1.14 It is submitted that CTH 8477 inter alia includes “Other machinery for moulding or otherwise forming” which includes tariff entry 8477 51 00 and 8477 59 00. Tariff entry 8477 51 00 provides “For moulding or retreading pneumatic tyres or for moulding or otherwise forming inner tubes” and tariff entry 8477 59 00 provides “Other”. The relevant entries of Heading 8477 are extracted below:

8477		Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter
	–	Other machinery for moulding or otherwise forming:
8477 51 00	– –	For moulding or retreading pneumatic tyres or for moulding or otherwise forming inner tubes
8477 59 00	– –	Other

4.1.15 It is submitted that the machine proposed to be imported by the Applicant cannot perform moulding or retreading of pneumatic tyres or moulding or forming of inner tubes. Therefore, the machine imported by the Applicant cannot be classified under tariff entry 8477 51 00.

4.1.16 Accordingly, the machine imported by the Applicant can be classified under residuary tariff entry 8477 59 00 i.e. “other”. Reliance in this regard is placed upon US Cross. Ruling issued to Menlo Worldwide Services having no. NY R01078 dated 22.12.2024, relevant portion of which is provided below for the ease of reference:

“In your letter dated November 22, 2004 you requested a tariff classification ruling on behalf of your client Cannon USA. The articles in question are described as metering machines, mold carriers and a mold press used in the production sofa various molded products. Descriptive literature was submitted.

The metering machines include low pressure units, identified as the “B-System” , which are suited for metering out foam materials used in the molding of articles such as gaskets, and high pressure units, identified as “A-Compact”, which are used to produce a range of polyurethane, foams, and the “Multi Easy Froth”, which is designed to introduce a controlled amount of liquid carbon dioxide to an existing polyurethane system. Based on the information made available, the metering units are essentially pumps designed for the volumetric control of the process liquids that they are designed to deliver.

You indicate that the metering units incorporate a mixing head, which is essentially a specialized valve, designed to control the flow and mixture of the materials used to produce the foams. One such mixing head is identified as the “Internet”, which features a special design co-injection chamber for the wetting of fillers. You also indicate that the mix ink heads may be imported separate and apart from the metering units.

It appears that a complete polyurethane foam molding system of subheading 8477.59.80, Harmonized Tariff Schedule of the United States (HTSUS) would include the “multidaylight” press and at least one mold carrier, metering machine and mixing head. Ms. Jackie Rose of Cannon USA, Inc. has indicated that Cannon does not import complete systems.

The applicable subheading for the metering units will be 8413.19.0000, HTSUS, which provides for other pumps fitted or designed to be fitted with a measuring device. The rate of duty is free.

The applicable subheading for the “Intertwist” and other mixing heads, when presented separately, will be 8481.80.9050, HTSUS, which provides for other taps, cocks, valves and similar appliances. The rate of duty will be 2 percent ad valorem.

The applicable subheading for the mold carriers and the “multidaylight” press will be 8477.90.8595, HTSUS, which provides for parts of machines for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter: other: other. The rate of duty will be 3.1 percent.”

4.1.17 From the above relevant extract, it is apparent that a polyurethane foam molding system will be classified under subheading 8477 59 where all the parts required to constitute the same are

imported and presented for clearance together. The above cross ruling has classified the parts in separate tariff entries because the mixing heads will be imported separately.

4.1.18 In the present case, the Applicant will import all the parts required for manufacturing of foam manufacturing machine together and will present the same for clearance together. Therefore, the foam manufacturing machine imported by the Applicant can be classified under the tariff entry 8477 59 00 i.e. “Other”.

c. Without prejudice to the above, the foam manufacturing machine can be classified under tariff entry 8477 80 90.

4.1.19 Without prejudice to above, it is submitted that the foam manufacturing machine can be classified under tariff entry 8477 80 90.

4.1.20 As provided above, foam manufacturing machine fall under the CTH 8477. Further, sub­heading 8477 80 provides for “other machinery” which inter alia includes tariff entry 8477 80 10 and 8477 80 90. Tariff entry 8477 80 10 provides for “machinery for making rubber goods” and tariff entry 8477 80 90 provides for “others” . The relevant entries of Heading 8477 are extracted below:

8477		Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter
8477 80	–	Other machinery:
8477 80 10	– – –	Machinery for making rubber goods
8477 80 90	– – –	Other
8477 90 00	–	Parts

4.1.21 In the present case, the foam manufacturing machine uses plastic for manufacturing PUR. Therefore, the same cannot be classified under Tariff entry 8477 80 10 as the same provides for machinery for making rubber goods. Thus, foam manufacturing machine can be classified under residuary tariff entry 8477 80 90 i.e. “Other”.

d. Without prejudice to the above, the foam manufacturing machine can be classified under tariff entry 8479 89 99.

4.1.22 Without prejudice to the above, the Applicant submits that the foam manufacturing machine can be classified under CTH 8479 which covers “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter.” The relevant entries of Heading 8479 are extracted below:

8479		Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter
8479 10 00	–	Machinery for public works, building or the like
8479 20	–	Machinery for the extraction or preparation of animal or fixed vegetable or microbial fats or oils
8479 20 10	– – –	Oil-seed crushing or grinding machinery including purifying tanks
8479 20 90	—	Other
8479 30 00	–	Presses for the manufacture of particle board or fibre building board of wood or other ligneous materials and other machinery for treating wood or cork
8479 40 00	–	Rope or cable-making machines
8479 50 00	–	Industrial robots, not elsewhere specified or included
8479 60 00	–	Evaporative air coolers
	–	Passenger boarding bridges
8479 71 00	– –	Of a kind used in airports
8479 79 00	– –	Other
	–	Other machines and mechanical appliances:
8479 81 00	– –	For treating metal, including electric wire coil-winders
8479 8 2 00	– –	Mixing, kneading, crushing, grinding, screening, sifting, homogenising, emulsifying or stirring machines
8479 83 00	– –	Cold isostatic presses
8479 89	– –	Other:
8479 89 10	– – –	Soap cutting or moulding machinery
8479 89 20	– – –	Air humidifiers or dehumidifiers (other than those falling under heading 8415 or 8424)
8479 89 30	– – –	Mechanical shifting machines
8479 8 9 40	– –	Ultrasonic transducers
8479 89 50	– – –	Car washing machines and related appliances
8479 89 60	– – –	Coke oven plants
8479 89 70	– – –	Machinery for the manufacture of chemical and pharmaceuticals goods
8479 89 80	– – –	Machinery for use in goods of Chapter 88 or 89
	– – –	Other:
8479 89 92	_ _ _ _	Briquetting plant and machinery intended for manufacture of briquettes from agricultural and municipal waste
8479 89 99	– – – –	Other
8479 90	–	Parts:
8479 90 10	– – –	Of machines for public works, building or the like
8479 90 20	– – –	Of machines for the extraction of animal or fruit and vegetable fats or oil
8479 90 30	– – –	Of machines and mechanical appliances for treating wood
8479 90 40	– – –	Of machinery used for manufacture of chemicals and pharmaceuticals
8479 90 90	– – –	Other

4.1.23 It is submitted that the foam manufacturing machine has an individual function of manufacturing PUR and the same is not specified or included anywhere in Chapter 84 of the Tariff. Therefore, same can be classified under CTH 8479.

4.1.24 It is submitted that the CTH 8479 includes various sub-headings such as “Machinery for the extraction or preparation of animal or fixed vegetable or microbial fats or oils”, “Passenger boarding bridges” and “Other machines and mechanical appliances”. It is submitted that the foam manufacturing machine proposed to be imported by the Applicant does not fall under any of the sub­heading.

4.1.25 It is submitted that as the foam manufacturing machine cannot be classified under any specific sub-heading under CTH 8479, the same can be classified under residuary sub-heading 8479 89 i.e. “other”.

4.1.26 Further, the sub-heading 8479 89 provides for various tariff entries. It is submitted that the machine under consideration cannot be classified under any of the specific tariff entries and therefore, the same can be classified under residuary tariff entry 8479 89 99 i.e. “other”.

4.2 Applicability of Rule 2(a) of the GRI.

4.2.1 As provided above, the foam manufacturing machine will be imported from China in CKD/SKD condition and will be assembled in India.

4.2.2 Rule 2(a) of GRI provides that any reference to an article shall be taken to include a reference to that article in an incomplete or unfinished state, provided that the incomplete or unfinished article possesses the essential character of the complete or finished article at the time it is presented for clearance. Furthermore, Rule 2(a) also provides that a reference to an article shall be taken to include that article in an unassembled or disassembled state at the time of its clearance. The relevant extract of Rule 2(a) of GI Rules is provided below for ready reference:

“Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as presented, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also be taken to include a reference to that article complete or finished (or failing to be classified as complete or finished by virtue of this Rule), presented unassembled or disassembled.”

4.2.3 Thus, upon a perusal of Rule 2(a), it can be observed that goods presented for clearance, even in an unassembled or disassembled form (i.e., CKD/SKD form), are to be classified under the heading applicable to the fully assembled goods.

4.2.4 In the present case, all the parts required for making foam manufacturing machine will be imported in CKD/SKD form and will be presented for clearance at the same time. Therefore, it is submitted that the parts of foam manufacturing machine imported in CKD/SKD condition will merit applicability of Rule 2(a) of GRI and accordingly, will be classified as foam manufacturing machine under respective tariff entry and will not be classified as parts.

4.3 WHETHER ANTI-DUMPING DUTY WILL BE APPLICABLE ON IMPORT OF FOAM MANUFACTURING MACHINE?

4.3.1 Notification No. 21/2025-Customs (ADD) dated 26.06.2025 (“Notification dated 26.06.2025”) has imposed Anti-Dumping Duty on import of plastic processing machines or injection molding machines used for processing and moulding of plastic materials, falling under tariff entry 8477 10 00 and 8477 90 00.

4.3.2 Further, note 2 of the Notification dated 26.06.2025 provides that product under consideration includes all kinds of plastic processing or injection moulding machines, having a clamping force not less than 40 tonnes and not more than 1500 tonnes. Note 2 of the Notification dated 26.06.2025 is provided below:

“Note 2 The scope of the product under consideration includes all kinds of plastic processing or injection moulding machines, having a clamping force not less than 40 tonnes and not more than 1500 tonnes. The scope of the product under consideration includes machines in fully assembled, semi knocked down (SKD), complete knocked down form (CKD), or a combination of SKD & CKD. The scope is further clarified below —

a. A plastic processing machine in semi knocked down stage shall mean a plastic processing machine which is not fully assembled but is transacted as a plastic processing machine with parts or sub-assemblies not fitted together and the machine is not ready to use. A semi knockdown machine shall also imply sub-assemblies namely clamping/clamp unit, injection unit with or without screw & barrel, machine base frame and fabrication frames/covers imported for injection moulding machine.

b. A plastic processing machine in completely knocked down stage shall mean a plastic processing machine in its incomplete or unfinished form, has the essential character of the complete machine when put together, and contains all components required for assembling the machines.”

4.3.3 As provided above, clamping force of 80 kilo newtons (approximately 8.02 tonnes) is applied for manufacturing PUR. The fact that clamping force of 80 kilo newtons is applied can be verified from technical details of the foam manufacturing machine. Snapshot of the relevant extract of technical details is provided below:

4.3.4 In light of the above, it is submitted that even if the foam manufacturing machine is classified under tariff entry 8477 10 00, Notification dated 26.06.2025 is not applicable to the present case as clamping force of 8.02 tonnes is applied for manufacturing PUR, whereas Notification dated 26.06.2025 is applicable only if clamping force of machines is 40 tonnes and above.

4.3.5 In view of above, the Applicant prays for a ruling concluding that ADD shall not be payable on import of foam manufacturing machine from China as Notification dated 26.06.2025 provides for imposition of ADD only if clamping force is 40 tonnes and above whereas the clapping force of the machine to be imported is 8.02 tonnes.

5. Port of Import and reply from jurisdictional Commissionerate:

The applicant in their CAAR-1 indicated that they intend to import the subject goods from 0/o The Commissioner of Customs (NS-V), Nhava Sheva. The application was forwarded to the jurisdiction of 0/o The Commissioner of Customs, NS-V, JNCH, Nhava Sheva for comments on 19.11.2025, 10.12.2025, 31.12.2025 and 21.01.2026.

However, no comments received from the said jurisdictional authority.

6. Details of Personal Hearing:

Ms. Srinidhi Gameshan, Authorised Representative and others appeared for PH in this case. They reiterated the contention filed with the application that the subject import goods (now imported) i.e. “Foam Production Line” comprising Metering machine and Dry side, both functioning conjointly to make a whole machine. That the subject goods merit classification under CTI-84771000; and alternatively, under CTI-84775900, or 84778090 under CTH 8477; or under CTH 8479. They also relying on US cross Ruling in which the subject goods are classified under CTI-84775900, whereas as per their submission the department assessed the B/E under CTI-84778090.

ii) They also contended that the subject goods for ease of transportation is to be imported under CKD condition with all components and satisfies Rule 2(a) of GRI.

iii) They also contended that the ADD on import of the said goods will not be applicable inasmuch as it does not fulfil criterion of Note-2 to the ADD. As the subject goods has 2X80Kn capacity that is equivalent (160Kn) to 16.32 Tonnes much below the threshold of 40 Tonnes.

Nobody appeared for hearing from the department side.

DISCUSSION AND FINDINGS

7. I have considered all the materials placed before me in respect of the subject goods. I have gone through the submissions made by the applicant during the personal hearing. I proceed to pronounce a ruling on the basis of information available on record as well as existing legal framework.

8. At the outset, I find that the issue raised in the question in the Form CAAR-1 is squarely covered under Section 28H(2) of the Customs Act, 1962, being a matter related to classification of goods and determination of ADD on the subject goods under the provisions of this Act. As in the instant case the issues that arise for determination are:

(i) Classification of the subject goods described as “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine)”; and to examine-

(ii) Applicability of Anti-Dumping Duty on the subject goods in terms of Notification No. 21/2025-Customs (ADD) dated 26.06.2025.

9. Before deciding the issue, let me deliberate on the legal framework prescribed in Customs Tariff Act, 1975, Chapter/ Section notes along with HSN explanatory notes. As per Rule 1 of GRI, the titles of Sections, Chapters and sub-Chapters are provided for ease of reference only; for legal purposes, classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes.

10. Rule 1 of the General Rules for Interpretation provides that the classification of goods shall be determined according to the terms of the headings of the tariff and any relative Section notes or Chapter notes and thus, gives precedence to this while classifying a product. Rules 2 to 6 provide the general guidelines for classification of goods under the appropriate sub-heading. In the event the goods cannot be classified solely on the basis of Rule 1, and if the headings and section or chapter notes do not otherwise require, the remaining Rules 2 to 6 may then be applied in sequential order.

I. CLASSIFICATION OF THE SUBJECT GOODS

A. Technical Nature and Functional Scope

11. The subject goods comprise a complete and integrated foam manufacturing system consisting of two principal sub-systems, namely:

• Metering Machine — comprising storage tanks, high-pressure metering pumps, mixing heads, robotic dispensing systems, and electronic controls (PLC/HMI); and
• Dry Side — consisting of a 32-station oval conveyor with mould carriers (cassette system), heating units, clamping arrangement, and synchronized control mechanisms.

12. From the technical description and process flow, the functioning of the machine may be summarized as under:

• Polyol and isocyanate (reactive liquid components) are stored, metered, and pressurized;
• These components are delivered in precise ratios to mixing heads;
• The mixed reactive material is dispensed/injected into mould cavities through robotic arms;
• The moulds, housed within cassette-based carriers, are closed and subjected to clamping force and controlled heating;
• A chemical reaction (polymerization) occurs inside the mould, resulting in formation of polyurethane foam;
• After curing, the mould opens and the finished molded product is removed.

13. Thus, the machine performs automated molding of polymer products by introducing reactive material into mould cavities, followed by shaping and solidification within the mould.

B. Applicability of Heading 8477

14. Heading 8477 Covers: “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere.”

The relevant tariff entries of CTH 8477 is produced as below:

15. Polyurethane foam is a polymer falling within the ambit of Chapter 39 of the First Schedule to the Customs Tariff Act, which covers “Plastics and articles thereof.” Further, polyol—being a primary input in the manufacture of polyurethane foam—is classifiable under tariff entry 3907 29 10. In view of the above, and considering that the subject machine is specifically designed for the manufacture of such polymer-based products, it is evident that the goods are appropriately classifiable under Heading 8477. The subject goods, being plastic processing machinery, are thus squarely covered under Heading 8477 of the Tariff.

C. Whether the Subject Goods are “Injection Moulding Machines” (CTH 8477 10 00)

16. The principal issue to be determined relates to whether the subject goods merit classification under tariff entry 8477 10 00 — “Injection moulding machines”.

17. In this regard, it is essential to understand the scope of the term “injection moulding machine” in trade and technical parlance. Injection moulding is a process involving:

• Introduction (injection) of material into a mould cavity;
• Conformation of the material to the shape of the mould;
• Solidification within the mould to produce a finished article.

18. Applicant has made submission that there are various types of injection moulding machines which inter alia includes “Reaction Injection Moulding Machines”. In common parlance, reaction injection moulding machine means a machine which uses low-pressure and low-temperature process that mixes two reactive liquid components (like polyol and isocyanate) and injects them into a mould, where they chemically react and solidify into a finished polymer. It is important to note that injection moulding is not restricted only to thermoplastic screw-type machines, but also includes reaction injection moulding (RIM) processes, wherein:

• Two or more liquid components are injected into a mould;
• These components chemically react within the mould;
• The reaction results in formation of a solid polymer in the desired shape.

19. In the present case, the following features are evident:

• The metering system injects controlled quantities of polyol and isocyanate into the mould;
• The injection is carried out through mixing heads and robotic dispensing units;
• The material enters the mould cavity in liquid form;
• Polymerisation occurs within the mould itself, leading to formation of polyurethane loam;
• The molded article takes the shape of the mould cavity.

20. Therefore, the essential characteristics of injection into a mould followed by in-mould formation of a finished plastic article are fully satisfied.

21. Further, the machine includes all the essential functional modules of an injection moulding system, namely:

• Injection/Metering Unit — high-pressure pumps and mixing heads;
• Moulding Section mould carriers and cavities;
• Clamping Mechanism — to hold moulds closed during reaction;
• Control Systems — PLC/HMI ensuring process precision.

22. The mere fact that the process involves in situ chemical reaction within the mould does not detract from the essential character of the operation as injection moulding. On the contrary, it represents a technologically evolved subset, namely reaction injection moulding (RIM), wherein polymer formation occurs post-injection. The tariff entry does not restrict itself to any specific injection technology or material form. Accordingly, the subject machine squarely falls within the scope of “injection moulding machines”. Additionally the The applicant has itself admitted, and unequivocally acknowledged unequivocally acknowledged that the imported machine satisfies the essential characteristics of a reaction injection moulding machine. Additionally, the applicant has itself admitted and unequivocally acknowledged that the imported machine satisfies the essential characteristics of a reaction injection moulding machine.

23. Accordingly, applying Rule 1 of the General Rules for Interpretation, the subject goods are appropriately classifiable under tariff item 8477 10 00 — that covers Injection moulding machines.

D. Alternative. Classifications:

26. The alternative classifications proposed by the applicant under CTH 8477 59 00, 8477 80 90, and 8479 89 99 have been duly considered. However, the same are found to be devoid of merit for the following reasons:

• CTH 8477 59 00 is a residual sub-heading covering “other moulding machines”. It is a settled position in law that where goods are squarely covered by a specific entry—in the present case the goods are very well covered under the description, “injection moulding machines” under CTH 8477 10 00—recourse to a residual entry is not tenable.
• CTH 8477 80 90 is in the nature of a general residual entry within Heading 8477, intended to cover only those machines which are not classifiable under any of the specific sub-headings therein. Once the subject goods are found to answer the description of a specifically enumerated category, their classification under a residual sub-heading is non-maintainable.
• CTH 8479 is a residuary heading applicable only to machinery not specified elsewhere in Chapter 84. In the facts of the present case, where the goods are appropriately and undoubtedly classifiable under Heading 8477 itself being Machinery for manufacture of products from plastics and not specified or included elsewhere, invocation of Heading 8479 is clearly unreasonable and against the scheme of the tariff

24. It is a well-settled canon of tariff interpretation, consistently upheld in judicial pronouncements, that a specific entry must prevail over a general or residuary entry (generally specialisms non derogate). The General Rules for Interpretation also mandate that classification shall be determined according to the terms of the headings and any relevant Section or Chapter Notes. Therefore, once the subject goods are found to be covered by a specific tariff entry, recourse to alternative or residuary classifications is legally not tenable and required to be rejected.

25. The above view is fortified by settled judicial precedents. In Dunlop India Ltd. v. Union of India, the Hon’ble Supreme Court held that when an article is classifiable under a specific entry, resort to a residuary entry is not permissible. Similarly, in Collector of Central Excise v. Wood Craft Products Ltd., it was held that classification must be determined on the basis of the description in the tariff, and specific entries take precedence over general ones. In Bharat Forge & Press Industries (P) Ltd. v. CCE, the Hon’ble Court reiterated that residuary entries can be invoked only when goods cannot be brought under any specific heading. The ratio of these judgments squarely applies to the present case, where the subject goods are specifically covered under CTH 8477 10 00, thereby excluding recourse to residual or alternative entries.

In view of the above judicial pronouncements and established interpretative principles, it is evident that once the subject goods are found to be specifically covered under CTH 8477 10 00, recourse to alternative or residuary entries such as CTH 8477 59 00, 8477 80 90, or 8479 89 99 will not sustain.

ON ANTI-DUMPING DUTY (ADD):-

26. The submissions advanced by the applicant seeking classification of the subject goods under CTH 8477 59 00 and claiming non-applicability of Anti-Dumping Duty (ADD) have been carefully examined in light of the statutory provisions, technical characteristics of the goods, and settled principles of tariff interpretation. The said contentions are found to be legally and factually untenable for the reasons elaborated hereunder:

A.1 The Subject Goods as “Other Moulding Machinery”

27. The applicant has sought to classify the subject goods under CTH 8477 59 00 as “other machinery for moulding or otherwise forming”. This contention is based on an erroneous appreciation of the functional identity and operational characteristics of the machine.

28. It is observed that the subject goods perform the core function of introducing (injecting) reactive material into mould cavities, followed by shaping and solidification within the mould. This sequence of operations constitutes the defining feature of an injection moulding process. Notably, the applicant has itself expressly admitted and unequivocally acknowledged that the imported machine satisfies the essential characteristics of a reaction injection moulding (RIM) machine.

29. Tariff entry 8477 10 00 specifically covers “Injection moulding machines”. ft is a settled principle of classification that where goods are classifiable under a specific entry, recourse to a general or residual entry—such as 8477 59 00—is impermissible.

30. Accordingly, classification of the subject goods under CTH 8477 59 00 amounts to a mischaracterization of a specifically described machine as falling within a residual category, which is contrary to the scheme and structure of the tariff.

A.2 Erroneous Distinction between Reaction Injection Moulding and Injection Moulding

31. The applicant has attempted to exclude the subject machine from the ambit of “injection moulding machines” on the ground that the process involves chemical reaction (polymerisation) rather than melting of plastic granules. However, the applicant has itself admitted and unequivocally acknowledged that the imported machine possesses the essential characteristics of a reaction injection moulding machine.

32. The above distinction is artificial and unsupported by the tariff framework. The description under CTH 8477 10 00 does not impose any restriction with respect to the nature of the material, its physical state, or the specific technology employed for injection.

33. In contemporary industrial practice, reaction injection moulding (RIM) is a well-recognised and commercially accepted variant of injection moulding, wherein liquid components are injected into a mould and undergo in situ chemical reaction to form a solid polymer.

34. In the present case, the machine:

• injects (or releases, through robotic systems) liquid components into the mould carrier/cassette;
• shapes the material within the mould carrier/cassette; and
• produces a finished article upon curing.

35. Thus, the essential character of the process remains that of injection moulding. The distinction sought to be drawn by the applicant is therefore not relevant for classification purposes and is liable to be rejected.

A.3 Functional Composition of the Machine

36. The subject goods comprise all essential elements of an injection moulding system, including:

• Injection/metering unit (pumps and mixing heads and robots that pours into mould carrier/cassette);
• Moulding section (32 mould carrier/cassettes);
• Clamping mechanism (pneumatic air bag system);
• Automated control systems.

37. The presence of these components, functioning in an integrated manner, clearly establishes that the machine is not merely a generic moulding device but a complete injection moulding system.

38. The applicant’s classification under 8477 59 00 fails to account for this integrated functional identity and instead isolates certain process aspects, which is not permissible

A.4 Misplaced Reliance on Foreign Ruling

39. The applicant has relied upon a US Cross Ruling to support classification under a subheading equivalent to 8477 59.

40. This reliance is misplaced for the following reasons:

• Classification under the Indian Customs Tariff is governed strictly by the provisions of the Customs Tariff Act, the General Rules for Interpretation, and relevant Section/Chapter Notes;
• Foreign rulings, including those under the US HTSUS, are not binding and have only limited persuasive value;
• The cited ruling itself distinguishes between individual components and complete systems and does not conclusively support classification under 8477 59 00 where a complete moulding system is presented.

41. Therefore, the said reliance does not advance the applicant’s case.

A.5 Impermissible Resort to Residual Entries

42. The applicant has alternatively proposed classification under residual entries such as CTI I 8477 80 90 and 8479 89 99.

43. It is a settled principle that residual entries can be invoked only when goods are not classifiable under specific entries.

44. Since the subject goods are squarely covered under the specific entry “Injection moulding machines” under CTH 8477 10 00, recourse to residual entries is legally untenable.

E. Applicability of Rule 2(a) of GRI (CKD/SKD Imports)

45. It is an admitted fact that the subject goods are imported in CKD/SKD condition with all components presented together.

46. Rule 2(a) of the GR1 provides that:

• Goods presented unassembled or disassembled, but having the essential character of the complete article, shall be classified as the complete article.

47. In the present case:

• The metering machine and dry side together constitute a fully functional foam production line;
• All essential components are imported simultaneously.
• The system clearly possesses the essential character of a complete injection moulding machine.

48. Therefore, the goods merit classification as a complete machine under CTH 8477 10 00 and not as parts.

II. APPLICABILITY OF ANTI-DUMPING DUTY

49. Notification No. 21/2025-Customs (ADD) dated 26.06.2025 imposes Anti-Dumping Duty on:

• Plastic processing / injection moulding machines;
• Falling under tariff entries 8477 10 00 and 8477 90 00;
• Having clamping force not less than 40 tonnes and not more than 1500 tonnes.

50. It is further pertinent to note that Note 2 of the said Notification explicitly defines the scope of the “product under consideration” and provides as under:

“”Note 2 : The scope of the product under consideration includes all kinds of plastic processing or injection moulding machines, having a clampingforce not less than 40 tonnes and not more than 1500 tonnes. The scope of the product under consideration includes machines in fully assembled, semi knocked down (SKD), complete knocked down form (CKD), or a combination of SKD & CKD. The scope is further clarified below —

a. A plastic processing machine in semi knocked down stage shall mean a plastic processing machine which is not fully assembled but is transacted as a plastic processing machine with parts or sub-assemblies not fitted together and the machine is not ready to use. A semi knockdown machine shall also imply sub-assemblies namely clamping/clamp unit, injection unit with or without screw & barrel, machine base frame and fabrication frames/covers imported for injection moulding machine.

b. A plastic processing machine in completely knocked down stage shall mean a plastic processing machine in its incomplete or unfinished form, has the essential character of the complete machine when put together, and contains all components required for assembling the machines.”

51. A plain reading of the above Note makes it abundantly clear that the scope of the notification is deliberately broad and technology-neutral, encompassing all forms and configurations of injection moulding machinery, irrespective of their state of assembly. The governing criteria are the functional identity of the machine as a plastic processing/injection moulding system and its clamping force falling within the specified range. The express inclusion of CKD/SKD forms, coupled with detailed clarifications, evidences the clear legislative intent to preclude circumvention of Anti-Dumping Duty through fragmented or unassembled imports. The subject machine is unequivocally a plastic processing machine and squarely qualifies as an injection moulding machine, thereby satisfying the conditions stipulated in the notification.

52. It is pertinent to note that the levy of Anti-Dumping Duty under Notification No. 21/2025- Customs (ADD) dated 26.06.2025 emanates from the findings of the Designated Authority in the Directorate General of Trade Remedies (DGTR), who, upon detailed investigation, concluded that imports of plastic processing / injection moulding machines within the specified clamping force range the domestic industry. The scope of the product under consideration, as determined by the DGTR, includes injection moulding machines of various configurations and technological variants, including machines imported in CKD/SKD condition and systems designed for industrial-scale production. The determination of clamping force as a key parameter reflects the production capacity and industrial application of such machines, rather than their internal configuration or distribution of force across components.

53. Accordingly, the interpretation of the notification must be aligned with the object and purpose of the DGTR findings, which is to provide a level playing field to the domestic industry against unfairly priced imports of high-capacity injection moulding machinery. Any interpretation that artificially fragments the machine into individual stations or disregards its aggregate operational capacity would defeat the intent of the investigation and render the remedial measure ineffective. This position is further reinforced by Note 2 of the notification, which mandates a broad and inclusive understanding of the product scope, covering all configurations of machines possessing the essential character and functional attributes of plastic processing machine or injection moulding systems. Therefore, a purposive and holistic interpretation, consistent with the DGTR findings, warrants that multi-station integrated machines such as the subject goods be assessed on the basis of their total effective clamping capacity and overall functional identity.

54. Determination of Clamping Force

55. The relevant portion of technical specifications of the subject goods regarding clamping force is produced verbatim as below:

2,1.4 Cassette system

32 Mould Carrier/Cassettes

Each mould carrier consisting of:

2 (two), integrated pivot bearings for tilting mould carrier lid

2 (two), integrated pivot bearings for tilting mould carrier frame

base frame, to carry the air bag support and the lower platen

parted bottom plate (two halves) each with four taps (M12) for mould

fixing, made in carbon steel

Platen thickness 15mm

4 (four), pneumatic air bags, 2 (two) for each platen,

selectable for individual or combined parallel stroke

1 (one) upper frame, built as rigid steel frame for mould fixing. Mould

fixing flexibility from front to back side

3 (three), mechanical locking latches (middle and as far as possible

outside the carrier)

Larger mould size possible in between the front latches

Portable with fork lift

Mechanical system to secure 0′ position in pour and cure area

other part of the multi coupling for water and air

55. From the technical specifications, it is observed that the machine is configured as a cassette-based multi-station moulding system comprising 32 mould carrier/cassettes arranged on a continuous conveyor. Each cassette is a self-contained mould holding unit consisting of a rigid base frame, upper frame for mould fixing, pneumatic air bag system, platens, and mechanical locking arrangements, enabling independent moulding operations at each station.

56. The technical data of each cassette system indicates that:

• Each mould carrier is equipped with 4 pneumatic air bags, arranged as 2 air bags per platen, capable of operating individually or in combined parallel stroke;
• The system provides a parallel pneumatic stroke of approximately 470/445 mm with platen thickness of 15 mm;
• The clamping mechanism operates through pneumatic pressure, generating a force of 2 x 80 kN per mould at a specified stroke condition;
• The mould fixing area is approximately 2 x 850 x 900 mm, designed to accommodate moulds up to 750 kg total weight;
• The cassette incorporates mechanical locking latches and rigid steel frames ensuring structural integrity during pour and cure operations.

57. Accordingly, each moulding station (cassette) is capable of generating a clamping force of 2 x 80 kN, i.e., 160 kN (approximately 16.32 tonnes) per mould. The machine consists of 32 such stations operating simultaneously as part of a continuous and integrated production system.

58. The applicant has contended that since the clamping force per mould is approximately 16.32 tonnes, the same falls below the minimum threshold of 40 tonnes prescribed under the notification.

59. However, the subject machine is not a standalone single-mould unit, but a multi-station integrated moulding system, wherein:

• Each cassette functions as an independent moulding unit;
• All 32 stations operate in a synchronized manner as part of a single production line;
• The machine is designed and supplied as one composite system for industrial-scale manufacturing.

60. In such cassette-based, multi-station systems, the determination of clamping force cannot be confined to an individual mould or cassette in isolation. The machine is engineered and commercially understood as a single integrated unit, wherein multiple moulding stations collectively contribute to the overall production capacity. Therefore, the effective clamping capacity must be assessed with reference to the machine as a whole.

61. Accordingly, the total effective clamping force is computed as:

• 32 tonnes x 32 stations = approximately 522.24 tonnes

B. Applicability of Notification

62. The aggregate clamping force of approximately 24 tonnes falls squarely within the range of 40 tonnes to 1500 tonnes specified in the notification.

63. Further, the notification expressly covers:

• Injection moulding machines;
• Machines imported in CKD/SKD condition; and
• Machines possessing the essential character of complete machinery.

64. As already established:

• The subject goods are classifiable under CTH 8477 10 00;
• The goods are imported in CKD/SKD form but constitute a complete machine;
• The clamping force, when assessed on a cumulative basis, satisfies the prescribed threshold.

65. In the present case, the Applicant proposes to import “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine)” (Part No. CAP0003805) from China PR, supplied by Krauss Maffei Machinery (China) Co. Ltd., as evidenced by the purchase order placed on record. As already established, the subject goods are classifiable under CTI1 8477 10 00 and possess an effective clamping force of approximately 24 tonnes. The goods, therefore, squarely fall within the scope of the product under consideration as defined in Note 2 of the said notification, which expressly includes injection moulding machines, including those imported in CKD/SKD condition.

66. The rate of Anti-Dumping Duty under the said notification is specified in the Table appended thereto, on an ad valorem basis as a percentage of CIF value, depending upon the producer/exporter. The relevant table of the said Notification No. 21/2025-Customs (ADD) dated 26.06.2025 is produced as below:

Table

S No.	Tariff Items	Description of the goods	Country of origin	Country of export	Producer	Duty as % of CIF value
(1)	(2)	(3)	(4)	(5)	(6)	(7)
1.	8477 10 00 or 8477 90 00	Plastic Processing Machinery	China PR	Any country including China PR	Dongguan Fu Chun Shin Plastic Machinery Manufacture Co., Ltd. and Fu Cher Shin (Ningbo) Machinery Manufacture Co., Ltd	48%
2.	-do-	-do-	China PR	Any country including China PR	Chen Hsong Machinery Co Ltd, Chen Hsong Sales & Marketing (Shenzhen) Co., Ltd, Chen Hsong Machinery (Ningbo) Co., Ltd., Chen Hsong Machinery (Shenzhen) Co., Ltd, Foshan Shunde Chen De Precision Machinery Co., Ltd.,Foshan Shunde Chen De Plastics Machinery Co., Ltd	27%
3.	-do-	-do-	China PR	Any country including China PR	Yizumi Precision Molding Technology Co., Ltd., Yizumi High Speed Packaging Technology Co., Ltd, Yizumi Precision Machinery (HK) Co., Limited, Yizumi Precision Machinery (Suzhou) Co., Ltd	35%
4.	-do-	-do-	China PR	Any country including China PR	Husky Injection Molding Systems Shanghai Ltd	0%
5.	-do-	-do-	China PR	Any country including China PR	Any producer other than producers mentioned at S No. 1,2,3 and 4 above	63%
6.	-do-	-do-	Any country other than China PR and Taiwan	China PR	Any producer	63%
7.	-do-	-do-	Taiwan	Any country including Taiwan	Chen Hsong Machinery Taiwan Co., Ltd.	39%
8.	-do-	-do-	Taiwan	Any country including Taiwan	Huarong Plastic Machinery Co., Ltd	0%
9.	-do-	-do-	Taiwan	Any country including Taiwan	Any producer other than producers mentioned at S No. 7 and 8 above	53%
10.	-do-	-do-	Any country other than China PR and Taiwan	Taiwan	Any producer	53%

It is observed that Krauss Maffei Machinery (China) Co. Ltd. is not among the specifically listed producers covered under Serial Nos. 1 to 4 of the Table. Accordingly, the subject imports would fall under the residual category applicable to “any producer other than those specified”.

67. Therefore, in terms of Serial No. 5 of the said notification, imports of the subject goods originating in or exported from China PR from producers other than those specifically listed attract Anti-Dumping Duty at the rate of 63% of CIF value.

68. In view of the above, the subject goods proposed to be imported by the Applicant from Krauss Maffei Machinery (China) Co. Ltd. are squarely covered under the scope of Notification No. 21/2025-Customs (ADD) dated 26.06.2025, and are liable to Anti-Dumping Duty at the applicable rate of 63% of CIF value.

C. Conclusion on Applicability of ADD

69. In view of the foregoing, it is unambiguously established that the subject goods fall within the scope of “plastic processing or injection moulding machines” as contemplated under the said notification, and satisfy all prescribed conditions for levy of Anti-Dumping Duty.38. Accordingly, Anti-Dumping Duty under Notification No. 21/2025-Customs (ADD) dated 26.06.2025.  is applicable to the subject imports.

70. Summary

(i) The goods described as “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine)” are, on the basis of their design, configuration and functional characteristics, clearly identifiable as a plastic processing/injection moulding machine and are correctly classifiable under Tariff Item 8477 10 00.

(ii) In terms of Rule 2(a) of the General Rules for Interpretation, goods imported in CKD/SKI) condition are required to be treated as complete machinery. This position stands further reinforced by Note 2 of Notification No. 21/2025-Customs (ADD) dated 26.06.2025, which expressly includes machines imported in fully assembled, SKD, CKD or combined forms, provided they possess the essential character of a complete injection moulding machine.

(iii) A plain reading of Note 2 establishes that the scope of the notification is deliberately broad and technology-neutral, covering all forms and configurations of plastic processing or injection moulding machines. The determining criteria are the functional identity of the machine and its clamping force within the specified range, and not the manner of assembly or distribution of components.

(iv) The effective clamping force of the subject machine, when assessed on a cumulative basis across 32 integrated stations, each exerting 160 kN (approximately 16.32 ‘tonnes), works out to approximately 522.24 tonnes, which squarely falls within the prescribed range of 40-1500 tonnes.

(v) Accordingly, the subject goods satisfy all the conditions stipulated in Notification No. 21/2025-Customs (ADD) dated 26.06.2025. including the scope as defined under Note 2 thereof, and are liable to Anti-Dumping Duty irrespective of their precise tariff classification, since the levy is governed by the product scope as defined by the Designated Authority and the notification.

71. On the basis of the facts and circumstances of the case, the foregoing discussions, and observations, I reach to the following conclusions:

(i) The subject goods, namely “Foam Production Line with 32 Station Conveyors (including Dry Side and Metering Machine)”, are fully covered and, by virtue of all their features, constitute an injection moulding machine. They are classifiable under Customs Tariff Heading 8477, specifically under Tariff Item 8477 10 00 of the First Schedule to the Customs Tariff Act, 1975.

(ii) The subject goods proposed to be imported by the Applicant from Krauss Maffei Machinery (China) Co. Ltd. are squarely covered under the scope of Notification No. 21/2025-Customs (ADD) dated 26.06.2025. and are liable to applicable Anti-Dumping Duty.

I accordingly rule.